On September 29, 2016, the Singapore Court of Appeal ruled[3] in Sanum Investments Limited v. Lao People’s Democratic Republic that the bilateral investment treaty (BIT) between the People’s Republic of China and Laos applied to Macau, finding that Macao-based company Sanum Investments could seek redress through the BIT against the Laos government for its claim of capital investment benefit losses through unfair taxes. The BIT did “not expressly state whether it would or would not in due course apply to Macau” when it was signed in 1993, and Macao became a territory of China in 1999. A main point of contention was whether or not certain notes verbales between Laotian and Chinese diplomats that expressed “the view that the PRC-Laos BIT did not apply to Macau" effectively defined the scope of the BIT. The Court was unconvinced, instead reasoning that “because a treaty is binding in respect of the entire territory of a State, the [Moving Treaty Frontier] Rule presumptively provides for the automatic extension of a treaty to a new territory as and when it becomes a part of that State.”